OSHA is still fulfilling its mission promoting worker and workplace safety. Safety, Amputations, and Planned Inspections led the OSHA inspection categories for NAICS 332721 so far this year.

At PMPA we take a look twice a week at the OSHA inspections posted online for our industry. In the event that one of our members is on that list, we call immediately to offer our assistance. If it is a non-member, we look to learn what vulnerabilities are being encountered in the industry shops not belonging to PMPA.

The single largest category were for “Safety” – 15 of 53, 28% of all inspections posted.

Go figure.

The second most frequent category was “Amputations“-12 of 53, 23%.

This really is aggravating. There is no excuse for anyone to be losing body parts.We need to contact our people immediately to review the basics about pinchpoints, rotating equipment, and the pointlessness of trying to stop a lathe with our fingers or thumb.

I won’t display the photos but if you want to see what a drill can do to a human hand click this link: Graphic Image

Programmed (planned ) Inspections were third with 7 of 53 or 13%. Routine enforcement is still a “real thing” at OSHA.

Complaints came in at fourth with 4 out of 53 inspections being initiated as a result of a complaint- 8% of inspections due to complaints..

Health tied with Complaints at 4 inspections out of 53- 8% of inspections due to occupational health concerns

Rounding out the ten causes were Noise, Reinspections, Accidents, Referrals, and Inspections.

The Precision Machined Products Association (PMPA) filed official comments opposing an Administration proposal to place additional burdens on employers while loosening injury reporting requirements on employees.

Clarity, not confusion, should be the work product coming out of here.

On August 14, 2014, the U.S. Occupational Safety and Health Administration (OSHA) issued a Supplemental Notice to a pending rule to make injury and illness reports public which becomes final in March 2015. The notice reframes Employee injury reporting as a “right” rather than a “duty.”

Reporting of injuries and illnesses is not a right. It is an obligation of the employee to report; and a responsibility of the employer to record, investigate, and take appropriate remedial actions to retrain as necessary and to remove any hazards so identified.

Employee Duty

“We are very concerned that the as-yet unpublished regulatory text will actually become an obstacle to our ability to manage safety and hazard identification in manufacturing facilities,” said Rob Kiener, PMPA Interim Executive Director. “By changing the understanding of an employee’s “obligation to report injuries and illnesses” to a “right to report,” OSHA allows workers the discretion to not report while maintaining the burden on employers,” continued Mr. Kiener.

For these reasons, and the reasons given in our submitted letter, earlier comments, and testimony, the PMPA urged OSHA to withdraw both the proposed regulation and Supplemental Notice.

In the absence of actual regulatory text for us to review, OSHA creates only uncertainty regarding employers’ duties and obligations.

Furthermore, by ignoring OSHA’s own rule that employee compliance is a “duty,” OSHA potentially creates a means for employees to fail to report injuries and illnesses, with the proliferation of unrecognized hazards in workplaces across the country as a probable result.

In my experience these are the three prime causes for accidents and injuries in our manufacturing plants.

Who authorized this?

Failure to wear personal protective equipment.

Unauthorized use of tools, machinery or vehicles.

Failure to lockout/tagout when performing non routine work on equipment.

While it is personal responsibility to wear personal protective equipment, use only tools and equipment for which one has been trained and authorized, and to avoid hazards by not performing work on operating equipment, it is nevertheless management’s responsibility to assure that workers comply.

What have you done this week to make certain that your employees know that they are accountable for their personal safety?

“Rigging equipment for material handling shall be inspected prior to use on each shift and as necessary during its use to ensure that it is safe. Defective rigging equipment shall be removed from service.”- OSHA 1926.251(a)(1)

Fabric and cable slings are widely employed in our shops to lift and move bundles of bar stock in particular, as well as scrap totes, pallets, and other equipment when needed.

They often carry weights as much as 5 tons. over valuable equipment, and in the vicinity of employees.

A failed sling could cause thousands, or hundreds of thousands of dollars in damage as well as potential injuries.

In June, OSHA issued an enforcement memorandum instructing their CSHO’s to “be mindful of whether the employer has provided and maintained adequate means of egress from work areas, eg., adequate number of exit routes are provided, exit routes are free and unobstructed, and exit doors are not locked.”

Here are some training materials from Ohio Bureau of Workmen’s Comp for training in this area.

Slips, trips and falls- here are some facts to help you with training for your team.

We are currently working on our analysis of the 2013 Spring Regulatory Agenda which includes an item “Walking Working Surfaces and Personal Fall Protection Systems (Slips Trips and Fall Protection)” shown as Final Rule due for November 2013.

PMPA members will receive a report on each of the agenda items applicable to our industry.

Welcome to our blog, Speaking of Precision. As Director of Technology and Industry Research for PMPA, I bring 38 years of hands-on experience in areas of manufacturing, quality and steelmaking. I help answer "HOW?","WITH WHAT?" and "REALLY?"